An analysis of the Green Book's international tax enforcement provisions for U.S. persons

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An analysis of the Green Book's international tax enforcement provisions for U.S. persons

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An analysis of the Green Book's international tax enforcement provisions for U.S. persons

This article examines the Green Book's international tax enforcement provisions for U.S. persons, including: strengthening the existing "qualified intermediary" system to crack down on tax evasion; impose significant tax withholding on transactions involving nonqualified intermediaries or foreign legal entities (non-QIs); additional reporting and disclosure of foreign financial accounts and foreign business entities by financial institutions and U.S. persons; impose negative presumptions for U.S. persons or non-QIs for failure to file a foreign bank account report (FBAR); impose negative presumptions regarding U.S. withholding tax on fixed, determinable, annual, or periodical (FDAP) payments to certain foreign entities; extend statute of limitations for certain reportable cross-border transactions and foreign entities to six years after filing FBAR information and returns; impose 40-percent accuracy-related penalties on understatements of income tax involving undisclosed foreign accounts; improve the foreign trust penalty; money laundering, non-income tax issues and state and local follow-on impact; sharing of FBAR information by international and state and local law enforcement and banking and securities regulators; and grant of enforcement tools to prosecute international tax evasion

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In: Taxes - the tax magazine. - Chicago. - Vol. 87 (2009),

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International

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English

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An analysis of the Green Book's international tax enforcement provisions for U.S. persons